Advancing The Profession of Pharmacy

Incident-to Billing CPT Codes for Consultant Pharmacists

by | Aug 10, 2018 | Consulting Pharmacist Education


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One of the most frequently asked questions I get about billing for pharmacist services is “How can a consultant pharmacist use the incident to billing codes in an ambulatory care clinic?”

The easy rule of thumb is to know whether that service is beholden to the direct supervision (aka. Incident-to criteria) or the general supervision requirements.

When implementing a new service as a consultant pharmacist there are a few things to keep in mind regarding the supervision of auxiliary personnel.

1. Incident to billing codes use must fit incident to billing requirements for direct supervision

These services must be performed under direct supervision – The physician must be in the office suite/building.

  • incident-to CPT codes for ambulatory care clinics 99211-99214


2. Billed at 100% physician’s fee schedule and must be face-to-face.

99211 – nurses’ visit – 5 minutes – no medical decision making
99212 – 10 minutes – straightforward/little to no medical decision making
99213 – 15 minutes – low level of medical decision making
99214 – 25 minutes – moderate level of medical decision making

3. Different Medicare Administrative Contractors (MACs) have different requirements regarding auxiliary or non-physician personnel.

Also check your state pharmacy practice act and the language around collaborative practice agreements


Consultant pharmacists can use the incident to CPT codes 99211-99124 to bill through the physician’s NPI under the direct supervision of a collaborative physician if the MAC and state’s pharmacist scope of practice act allows for it.

What services are you dreaming of implementing in 2019?

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About the Author

Blair Thielemier, PharmD, is a business development consultant specializing in pharmacist-led billing models. She has set the industry standard for virtual pharmacy conferences with the Elevate Pharmacy Virtual Summit in 2017. She has consulted with national pharmacy organizations, drug wholesalers, point of sale companies, and Fortune 5 health insurers. She has books and online courses available for individuals looking to leverage their pharmacy knowledge into monetized clinical programs at She speaks internationally about trends in leveraging pharmacists to improve value-based care.


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